Opinion
26842-21
02-21-2023
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan Chief Judge
On December 8, 2021, respondent filed in the above-docketed case a Motion to Dismiss for Lack of Jurisdiction, on the grounds that no Notice of Certification of Your Seriously Delinquent Federal Tax Debt, as authorized and required by section 7345 of the Internal Revenue Code (I.R.C.) to form the basis for a petition to this Court, had been sent to petitioner, nor had respondent made any other determination with respect to petitioner's tax years that would confer jurisdiction on the Court, as of the date the petition herein was filed. Although the Court directed petitioner to file an objection, if any, to respondent's motion to dismiss, petitioner has failed to do so. Mail sent to petitioner has also been returned to the Court by the U.S. Postal Service as undeliverable.
Upon due consideration, it is
ORDERED that respondent's Motion To Dismiss for Lack of Jurisdiction is granted, and this case is dismissed for lack of jurisdiction.